MPP also submitted lengthy Technical Comments on the FDA draft. MPP’s comments were prepared by its consultant, Dr. Edward Groth, who worked as a senior scientist for Consumers Union for nearly 25 years on environmental health, food safety and risk communication. Dr. Groth emphasized, “While FDA’s analysis suggests that the benefits outweigh the risks for the average person, that point is misleading. The focus instead should be on ways to ensure benefits while minimizing risks—a “win/win” solution—by educating consumers to choose low-mercury fish.” Using data from the FDA’s own analysis, MPP’s comments show that tuna fish alone accounts for 37 percent of all the mercury in the American diet, and about 20 other varieties of fish and shellfish are also relatively high in mercury. But there is plenty of good news: Two-thirds of the total market for fish and shellfish is low in mercury, and 9 of the 11 top-selling items are low-mercury choices.